ML20046D137
| ML20046D137 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 08/10/1993 |
| From: | Cross J PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9308160186 | |
| Download: ML20046D137 (9) | |
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Portland General ElechicCorpw I
b James E. Cross f-Vice President and Chief Nuclear Officer August 10,1993 Trojan ibiccr Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington DC 20555
Dear Sirs:
Response to NRC Request for Information Regarding Request for Exemption from the Requirements of 10 CFR 50.120, l
Trainine and Oualification of Nuclear Power Plant Personnel l
l The purpose of this letter is to provide Portland General Electric Company's (PGE's) response to l
the NRC's request for plant-specific information (NRC letter dated June 25,1993) regarding implementation of the Training Rule (10 CFR 50.120), and to request specific exemption, in accordance with 10 CFR 50.12, from the requirements of the Training Rule. PGE believes that the existing training programs incorporate the instructional requirements necessary to provide qualified personnel to maintain the Trojan facility. Developing and maintaining a Systems Approach to Training (SAT) program that complies with 10 CFR 50.120 would present an undue financial and administrative hardsMp and would not serve the underlying purpose of the rule.
Attachment I provides the plant-specific information, as requested by the June 25 NRC letter, to support an NRC initiative to grant exemptions from the training rule for licensees of plants in the decommissioning process. A formal request for exemption from the requirements of 10 CFR 50.120 regarding the training and qualification of nuclear power plant personnel has been prepared and is enclosed as Attachment II to this letter.
Sincerely, h4 S. M. Quennoz for J. E. Cross f
i PDR ADOCK 05000344 0
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-l Document Control Desk August 10,1993 Pace 2 Attachments l
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Mr. Bobby H. Faulkenberry Regional Administrator, Region V U. S. Nuclear Regulatory Commission Mr. David Stewart-Smith State of Oregon Department of Energy Mr. James Melfi NRC Resident Inspector Trojan Nuclear Plant L
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i Trojan ~ Nuclear Plant Document Control Desk Docket 50-344 August 10,1993
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. License NPF-1 Attachment I Page 1 of 3 RESPONSE TO NRC LETTER DATED JUNE 25,1993 IMPLEMENTATION OF THE TRAINING RULE ICFR 50.1201 Introduction This attachment provides plant-specific information, as requested by NRC letter dated June 25, 1993, to support an NRC initiative to grant exemptions from the training rule for licensees of plants in the decommissioning process. Specifically, PGE was requcsted :c indicate the specific reasons why SAT-based training programs meeting 10 CFR 50.120 requirements are unnecessary, and to describe the nature of the existing training programs at Trojan. The following provides this information.
Troian Trainine Procrams Until the plant shutdown, Trojan training programs for eight of the nine personnel categories included in 10 CFR 50.120 were accredited by the Institute of Nuclear Power Operations (INPO). These training programs were based upon a Systems Approach to Training and/or INPO guideline documents. The objective of these training programs was to ensure highly -
qualified personnel to perform the significant number of complex activities and tasks required at
- an operating nuclear power plant.
Trojan has been shutdown since November 9,1992, and received a Possession-Only License on-May 5,1993. The training programs at Trojan currently reflect the considerable reduction in the number of complex activities and tasks associated with Trojan in the permanently defueled condition.
The following Jescribes the status of the training program for each personnel category included -
in the Training Rule.
Non-Licensed Operator Trojan has two categories of Non-Licensed Operator: Non-Certified Operator (NCO) and Certified Fuel Handler (CFH).
The term Certified Fuel Handler refers to those Nuclear Division staff personnel that supervise and/or perform duties necessary to ensure the safe handling and storage of nuclear fuel. On April 27,1993, the NRC approved the Trojan Nuclear Plant Certified Fuel Handler Training Program (PGE Topical Report PGE-1057). The program describes the personnel to whom the
. program applies, the areas in which training is provided, what constitutes certification, how a
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, Trojan' Nuclear Plant Document Control Desk Docket 50-344 August 10,1993 License NPF-1 Attachment I Page 2 of 3 certification is maintained, and required qualifications. The CFH training program consists of Fundamentals, Indoctrination, Systems, and On-The-Job Training (OJT). The OJT phase is-conducted such that the students demonstrate their practical abilities on systems and procedures in 1
the work environment under the direction of qualified CFH's. The program culminates with I
successful completion of both a written and an operating examination, i
The term Non-Certified Operator refers to those Operations Department personnel other than a CFH. An NCO may be qualified to stand watch in the Control Room. The NCO training
~l program is incorporated into the CFH training program. Successful completion of the Fundamentals, Indoctrination, and Systems portions of the CFH training program qualifies an indiviaual m. N C O.
Shift Super isor The Trojan Shift Manager position is the functional equivalent of the " Shift Supervisor" position described in 10 CFR 50.120. The term Shift Manager currently refers to Certified Fuel Handlers
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who are accountable for safe and efficient conduct of activities in the permanently defueled mode.
Based en the plant's shutdown status, and the limited number of tasks, the formal Shift Manager Training Program has been discontinued.
Due to the permanent cessation of power operations at Trojan, the Shift Technical Advisor position no longer exists. Elimination of the STA position makes the STA training program -
j unnecessary.
Instrument and Control Tecimician (I&C Technician); Electrical Maintenance Personnel; and Mechanical Maintenance Personnel
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The terms I&C Technician, Electrical, and Mechanical Maintenance Personnel refer to those Nuclear Division staff personnel that perform repair and testing of plant equipment. The current-training program designates specific Maintenance Department individuals to implement the training programs. The training program for each of these disciplines include Fundamentals,
.l Theory, Conduct of Maintenance, Tasks, and OJT.
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, Trojan Nuclear Plant Document Control Desk l
Docket 50-344 August 10,1993 l
License NPF-1 Attachment I l
Page 3 of 3 i
Radiation Protection Technician; Chemistry Technician Due to the reduction in programs and staffing following the permanent cessation of operations at Trojan, the duties of the Radiological Protection Technician and the Chemistry Technician were combined for those individuals who are qualified in both areas. The current staff is composed of Chemistry and Radiation Protection Technicians (C&RP Technicians) and Radiation Protection Technicians (RP Technicians). The current training program for C&RP Technicians and RP Te:hnicians designates Chemistry and Radiation Protection Department individuals (C&RP Technicians) to implement the training program. The RP Technician training program consists of Administrative, Fundamentals, Personnel Monitoring, Instruments, Exposure Control, Respiratory Protection, Plant Systems, Radioactive Material, Emergency Response, and OJT.
The C&RP Technician training program consists of the topics included under RP Technician training, and also includes additional training requirements in the areas of Chemistry, Health Physics, Spectroscopy, Chromatography, and Sewage Treatment.
Engineering Support Personnel The term Engineering Support Personnel refers to those Nuclear Division staff personnel, including first line supervisory personnel, involved in engineering and other technical support for Trojan, except Chemistry and Radiation Protection engineering support personnel. Engineering Support Personnel currently receive training, on an as-needed basis, in 10 CFR 50.59, Accident Analysis, Systems, Technical Specifications, and Procedure Technical Reviewer.
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r Trojan Nuclear Plant Document Control Desk Docket 50-344 August 10,1993 License NPF-1 Attachment II Page 1 of 4 REQUEST FOR EXEMPTION FROM TITLE 10 OF THE CODE OF FEDERAL REGULATIONS. PART 50.120 fl0 CFR 50.1201
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Reauest for Exemption i
The requirements of 10 CFR 50.120 direct each holder of an operating license for a nuclear power plant to establish, implement, and maintain a training program derived from a Systems Approach to Training (SAT) as defined in 10 CFR 55.4 for the following categories of nuclear power plant personneh j
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Non-Licensed Operator; 2.
Shift Supervisor; 3.
Instrument and Control Technician; 5.
Electrical Maintenance Personnel; 6.
Mechanical Maintenance Personnel; 7.
Radiological Protection Technician; 8.
Chemistry Technician; 9.
Engineering Support Personnel.
Portland General Electric Company (PGE) is seeking exemption, in accordance with the provisions of 10 CFR 50.12, from the SAT-based training program requirements of 10 CFR 50.120.
Backcround i
On January 4.1993, PGE announced the permanent cessation of power operations at the Trojan Nuclear Plant.. PGE has implemented specific reductions in staffing, procedures, and programs to levels commensurate for a plant in the permanently shutdown condition. These reductions reflect the fact that many plant systems and programs no longer are required to be maintained and operated with the plant in the shutdown, defueled condition. As a part of these reductions, Trojan staff has modified the training programs to reflect the permanent changes in the plant -
condition.
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Trojari Nuclear Plant Document Control Desk Docket 50-344 August 10,1993 License NPF-1 1 Page 2 of 4 Basis for Exemption Reauest The provisions of 10 CFR 50.12 allow specific exemptions from the requirements of 10 CFR 50 provided the exemptions are authorized by law, are consistent with the common defense and security, are accompanied by special circumstances, and do not present an undue risk to the public health and safety. PGE concludes that the activities sought to be conducted under this exemption request are clearly authorized by law, are consistent with the common defense and security, and do not present an undue risk to the public health and safety. PGE believes special circumstances exist with regard to the implementation of the Training Rule (10 CFR 50.120) as described below.
10 CFR 50.12(a)(2)(ii) states, " Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule;... "
As discussed in the NRC's regulatory analysis of the Training Rule, the anticipated benefits of the proposed rule were reductions in radiation exposure to both occupational workers and the public. The methodology used in the regulatory analysis for calculating the rule's expected l
effects on public health risk and occupational exposure and property losses from accidents was
'l based on core melt probabilities. Thus the rule's benefits of averted public and occupational i
doses from accidents are applicable to operating plants where a core melt accident is possible.
The Trojan Possession-Only License (POL) was issued on May 5,1993, precluding any possibility of a core melt at Trojan. Thus no benefits would be gained (by establishing, implementing, and maintaining the training rule) from averted public and occupational doses from accidents with Trojan in the permanently defueled condition.
Furthermore, there are a relatively small number of complex activities required to be conducted at a permanently defueled nuclear plant such as Trojan as compared to those required at a nuclear power plant licensed for power operations. For example, the majority of plant systems and equipment, which were required to be operable and maintained to protect the public health and safety when Trojan was licensed for power operation, are no longer required now that Trojan is in the permanently defueled, shutdown condition. With Trojan's spent fuel stored in the spent fuel pool, the principal tasks and activities performed on site are limited to those necessary to monitor and maintain the spent fuel pool and associated suppon equipment.
. PGE has concluded that the existing training programs at Trojan reflect the significant reduction-in the number of complex activities conducted at a permanently defueled facility, and as such provide adequate protection of the public health and safety.' Therefore, requiring PGE to comply with the requirements of the Training Rule would not serve the underlying purpose of the rule.
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~ Trojan Nuclear Plant Document Control Desk Docket 50-344 August 10,1993 License NPF-1 Attachment II Page 3 of 4 10 CFR 50.12(a)(2)(iii) states, ' Compliance would result in undue hardship or other costs that are sigmficantly in excess of those contemplated when the regulation was adopted. or that are sigmjicantly in excess of those incurred by others similarly situated;... "
PGE has performed an estimate of the costs of complying with 10 CFR 50.120; these costs include development and implementation of training and qualification programs meeting the requirements of the Training Rule, as well as annual costs of program maintenance and revision.
The development and implementation costs described herein do not include those costs that PGE -
previously expended to develop and implement accredited training programs in several of the affected personnel categories. The estimated burden associated with development and implementation of SAT-based programs at Trojan has been determined to be approximately five (5) people for six (6) months at a cost of approximately $150,000. The annual costs for maintaining SAT-based training programs in accordance with 10 CFR 50.120 are estimated to be approximately 2.0 full-time equivalents (FTE) at a cost of about $130,000 per year.
As illustrated above, the significant costs involved in the development and maintenance of SAT-based training programs meeting 10 CFR 50.120 requirements outweigh the projected benefits.
Because Trojan is a permanently shutdown facility, the limited resources at the site are dedicated to the safe storage of fuel and preparations for decommissioning of the facility. The costs involved in the development and maintenance of SAT-based training programs meeting 10 CFR 50.120 requirements would result in inefficient use of PGE resources. Therefore, PGE's compliance with the requirements of the Training Rule would result in undue financial and administrative hardship to both PGE and its ratepayers.
Conclusion Based upon the information above, PGE has concluded that the specific exemption requested herein is justified, will not present undue risk to the public health and safety, and is consistent with the common defense and security. Furthermore, such an exemption meets the requirements of 10 CFR 50.12(ii) in that establishing, implementing, and maintaining SAT-based training programs that comply with 10 CFR 50.120 does not serve the underlying purpose of the rule.
- Such an exemption also meets the requirements of 10 CFR 50.12(iii) in that compliance with the requirements to establish, implement, and maintain SAT-based training programs that comply -
with 10 CFR 50.120 would result in undue costs for a facility in the decommissioning process.
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l Trojart Nuclear Plant Document Control Desk
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Docket 50-344 August 10, 1993 1
- License NPF-1 Attachment II Page 4 of 4 Potential Environmental Impact
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Pursuant to the provisions of 10 CFR 50.12, PGE is requesting exemption to the requirements of 1
10 CFR 50.120 to establish, implement, and maintain a training program derived from a systems approach to training as defined in 10 CFR 55.4 for specific categories of nuclear power plant personnel.
2 The proposed exemption has no effect on the conduct of activities at Trojan. The existing training programs incorporate the instructional requirements necessary to provide qualified.
personnel to maintain the Trojan facility in the permanently defueled condition, with no change in type or quantity of radioactive or nonradioactive ef0uents, increase in the licensed power level,
. i or change in plant configuration. Therefore, the proposed exemption will not have a significant impact upon the environment.
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